Annex G:
Umbrella IEEs for “Umbrella” Projects
G.1 Umbrella projects and USAID’s Environmental Procedures
The basic procedures described in Chapters 1–4 of this manual assume that proposed activities are sufficiently well-defined that the screening process can be undertaken and, if necessary, an IEE can be prepared.
However, proposals often include activities that are not fully defined at the time the proposal is submitted. “Umbrella projects” are a common example of this situation. In an umbrella project, a number of small-scale activities are funded through subgrants under a larger project.
Umbrella projects are commonly used to implement community-driven development schemes. They provide a mechanism to fund community proposals for small-scale activities. They may also be used to fund micro and small enterprise subprojects.
Typically, a USAID partner organization receives overall funding for the umbrella project. The partner then functions as a subsidiary grantmaker, using a portion of the overall funding to award small-scale grants.
Under certain circumstances, however, USAID itself assumes the role of managing the subproject proposal and grant-making process.
In either case, the basic situation is the same: the project includes a large number of activities that are not well-defined at the time of the initial design and proposal. Under USAID’s Environmental Procedures as described in Chapters 1–4, all such “yet to be defined” activities must be deferred because insufficient information is available to write the IEE. And under a deferral, funds cannot be committed or expended.
Attempting to implement an umbrella projects using IEE deferrals would be difficult. Under a deferral, the IEE would need to be amended and re-approved as each sub-activity was developed. Each amendment would require approval by the USAID Bureau Environmental Officer in Washington. This would time-consuming, make the IEE so long as to unmanageable, and impose an impossible workload on USAID’s Washington Bureaus.
G.2 The “Umbrella IEE” for umbrella projects
The “Umbrella IEE” offers an alternative to the deferral. It permits projects with (1) a large number of activities that are (2) not-well-defined at the time of the proposal to be implemented in an expeditious manner while maintaining compliance with Reg. 216.
The umbrella IEE process functions as follows:
· A negative determination with conditions is requested for the small-scale, yet-to-be-determined subgrant activities contained in the project proposal.[1]
· The key condition is that a streamlined or simplified environmental review process is created for and applied to the proposed small-scale sub-activities.
This subsidiary environmental review process is applied to these small-scale activities as they are defined (i.e., when design and siting decision are being made).
Although simplified, this process must substantially satisfy the requirements of Reg. 216. However, most environmental review documentation is approved by the partner or the mission, not at the BEO level. BEO approval is only required when the subproject environmental review identifies activities high-risk activities or activities with significant potential for adverse impacts.
As with the Reg. 216 process, an activity cannot be implemented until the subsidiary screening and review process is complete, and the documentation has been approved.
The existence and application of the subsidiary environmental review process is one condition of the IEE. Other conditions include:
· Demonstrated PVO capacity to carry out environmental reviews (e.g., staff may be required to complete environmental compliance training),
· Applying environmental best practice to planning and design,
· Conducting monitoring and mitigation as appropriate, and
· Reporting on the status of environmental compliance as required or requested.
G.3 How is the subsidiary environmental review process established?
The subsidiary environmental review (ER) process established by an umbrella IEE is set out in an Environmental Review Form (ERF) and accompanying instructions for its completion.
The ERF instructions guide users through the subsidiary screening, review and mitigation process for each set of activities as they are designed. The ERF and the ERF instructions are normally an integral attachment to the approved IEE.
There is no single model of an ERF. The examples presented in the attachments to this annex are meant to be specifically tailored for the requirements of a particular set of activities and a particular national or regional context.
G.4 Who has the power to approve environmental documentation of sub-activities?
Umbrella IEEs are most frequently used when a partner organization receives overall funding for an “umbrella project” that includes a sub-granting process. The Partner organization then functions as a grantmaker, reviewing proposals submitted by communities, local government or other PVOs/NGOs.
Under each umbrella IEE, the respective Mission and Partner will determine what level of sub-activity review and approval will be carried out by the USAID Mission, if any. (As with all IEEs, the concurrence of the BEO is also required for the governing IEE.) The Partner should discuss approval requirements with the Mission when considering an “umbrella” IEE.
Approval of the “umbrella” IEE means that, in most cases, approval of the subsequent environmental reviews (for specific activities or generic sets of activities) is by the Partner or Mission. USAID/Washington concurrence is typically NOT required. The exception is if a proposed activity is high risk or appears likely to result in significant adverse impacts and the need for an Environmental Assessment.
G.5 Attachments
This Annex contains the following attachments
Attachment 1: Template and Guidance for Writing an Umbrella IEE
Attachment 2a: Explanation of the Sample Environmental Review Form (ERF) and ERF Instructions
Attachment 2b: Sample Environmental Review Form (ERF) and ERF Instructions AND
Sample Supplemental Screening Questions for Natural Resource Management Activities
G–1 March 2005
Attachment 1 to Annex G:
Template and Guidance for Writing an Umbrella IEE
Because an umbrella IEE or IEE component addresses activities for which specific information in not available, standardized umbrella IEE language can often be used.
This section provides general guidance and suggested language for an umbrella IEE. It assumes that the project involves subgrants by the lead partner (the proposing organization) to sub-recipients. It provides section-by-section advice on writing such an umbrella IEE around the basic IEE outline.
Note: This section supplements the basic concepts set out in Chapter 4, “Writing the IEE.” Note also that a sample umbrella IEE is provided in Annex D.
If you are using the subgrant review process as one component within a larger IEE, the template below will require appropriate modification.
IEE Section 1: Background and Project Description
General guidance / Model language1.1 Background
State the reasons why proposed activities are not well-defined.
(For example, because activities will be in response to participant generated needs and proposals.)
1.2 Description of Activities
Indicate the types of activities that are likely.
Describe the planned funding levels of the activities.
Describe disbursement and implementation arrangements, including whether the activities are food for work, monetization or entail grants to communities or groups.
Identify organizations involved in the activities and their roles.]
1.3 Purpose and scope of IEE
<no special guidance>
IEE Section 2: Country and Environmental Information
General guidance / Model language2.1 Locations affected
Briefly describe the environment of the location(s) in which the undefined activities will take place.
Depending on the nature of the proposal, the locations could include an entire country, several regions, scattered locations, or a specific region.
The environment includes physical, biological, health, socio-economic, and cultural aspects. Indicate general environmental issues and trends.
However, because not all locations for future interventions have been identified and because of the variety of environmental situations that might be encountered, this section of the IEE can be neither comprehensive nor detailed
2.2 National Environmental Policies and Procedures
<no special guidance>
IEE Section 3: Evaluation of Project/Program Issues with Respect to Environmental Impact Potential
General guidance / Model languageTo the extent that you have information, describe the generic kinds of environmental impacts associated with each activity or type of activity.
Note whether there are features of the general environment that make it more likely (or less likely) that such impacts are significant.
Take care to assess potential cumulative impacts where a number of activities are to be carried out in close proximity to each other or will add to the impacts of other public or private sector activities. / If your knowledge of potential environmental impacts is limited, insert the following or similar wording:
The physical and topographic conditions, climate, soils, and ecosystems as well as social and economic characteristics that could be encountered are quite variable.
Because the specific characteristics and locations of these activities are not definitive, the potential for adverse environmental impacts cannot be excluded until additional information about project design and location becomes available.
Therefore, each proposed activity will require environmental review as it is defined. This review will determine the specific nature and magnitude of potential impacts. The activities to be proposed share the common characteristic of being small in scale.
IEE Section 4: Recommended Determinations and Mitigation Actions (Including Monitoring and Evaluation)
In comparing the internal organization of an “umbrella IEE” with that of a “classic” IEE, it is Section 4 which differs most strongly. Under Section 4 of an umbrella IEE, the proposing organization and USAID commit to following specific procedures for screening, post-IEE environmental reviews, mitigation, and monitoring (see Figure G.1). The proposing organization and USAID also commit to promoting environmental assessment capacity building for their staff and partners.[2]:
General guidance / Model language /4.1 Mitigation actions and conditions
The intent of the mitigation actions and conditions detailed in this section is to assure that no subgrant activities with significant, adverse environmental impacts are implemented under this project:
4.1a Environmental Screening and Review Procedures
This section describes the subgrant environmental review procedures that will be used by the project.
Note: The model language provided assumes that the ENVIRONMENTAL REVIEW FORM provided in this Annex is used. / Environmental screening and review procedures will be adopted for all subgrant activities not defined at the time of the proposal.
These procedures are set out in the attached draft Environmental Review Form and accompanying Environmental Review Form instructions. [PROPOSING ORGANIZATION] will prepare or cause to be prepared the appropriate documentation for each activity.
Under these procedures, each activity in a subgrant will result in one of three screening results:
§ Very low risk
§ Moderate or unknown risk
§ High-risk
Activities found to be (1) high risk or (2) moderate/unknown risk will require completion of an environmental review. For each activity, the environmental review will result in one of three possible recommended determinations:
§ No significant adverse impacts
§ No significant adverse impacts given specified mitigation and monitoring
§ Significant adverse impacts
Final review and clearance authority for the environmental documentation form will lie with the Mission Environmental Officer (MEO), with two exceptions:
§ The environmental reviews and recommended determinations for any “high risk” activities will require clearance by the [Regional Environmental Officer (REO) (if one exists)] and the Bureau Environmental Officer (BEO).
§ Recommended determinations indicating “significant adverse impacts” will incur Regulation 216 (22 CFR 216) requirements for the conduct of an Environmental Assessment.
No subgrant funds will be awarded until environmental documentation for the subgrant activity has undergone final review and clearance.
This clearance is granted on the condition that all mitigation and monitoring measures specified in the environmental review are binding requirements.
The attached Environmental Review form is a draft. USAID/[COUNTRY] will facilitate the refinement of this form with [PROPOSING ORGANIZATION] [, the REO, if one exists] and the BEO to meet project needs.
4.1b Capacity-building for Environmental Review
The proposing organization should provide evidence that it has, or will acquire, sufficient capacity to complete the environmental screening and review process, and to implement mitigation and monitoring measures.
Capacity can be developed through a training program, such as USAID’s ENCAP Environmental Assessment and Environmentally Sound Design Course (www.encapafrica.org).
If partner organizations will be proposing and implementing subgrant activities, they too, must have sufficient capacity to fulfill the environmental screening and review requirements.
4.1c Adherence to environmentally sound design principles
The proposing organization must certify that it and its partners will follow environmentally sound design best practice in designing and implementing their activities, and in designing mitigation and monitoring measures.
Refer to the sources of guidance or expertise that will be used, including USAID’s Environmental Guidelines for Small-Scale Activities in Africa. / Proposing organizations and their partners will certify they are are following environmentally sound design principles and best management practice in designing their activities. Guidance consulted shall include:
· USAID’s Environmental Guidelines for Small-Scale Activities in Africa (2003) (See www.encapafrica.org)
· [Other appropriate project or sector-specific design or BMP resource guides]
4.1d Environmental Monitoring & Evaluation
Mitigation and monitoring measures specified in the environmental reviews submitted under procedures described in 4.1a are binding requirements. [PROPOSING ORGANIZATION] shall assure that these measures are implemented.
All periodic reports of the implementing partner to [USAID Country Mission] shall contain an environmental section. This section shall summarize:
§ The state of implementation of environmental mitigation and monitoring measures
§ Results of environmental monitoring and any unexpected impacts,
§ The success or failure of mitigation measures being implemented,
§ Any major modifications/revisions to the project, mitigative measures or monitoring procedures.
[USAID Country Mission]’s MEO and the Project Manager will be ultimately responsible for monitoring environmental impacts of all project-financed activities. This may include:
§ monitoring and evaluation of activities after implementation for unforeseen environmental impacts that may need to be mitigated. This process should be integrated into Mission field visits and consultations with [proposing organization]
§ review of the implementing partner’s reports with respect to results of environmental mitigation and monitoring procedures;·